State v. Cambrice, 202 So. 3d 482

Mark Cambrice was convicted of first‑degree robbery (LSA‑R.S. 14:64.1) and ultimately adjudicated a second felony offender and sentenced as a multiple offender to 40 years at hard labor after resentencing.
Petitioner filed a pro se application for post‑conviction relief raising: (1) Brady claim that the State withheld a time‑stamped surveillance disc and police reports; (2) claim that the trial court refused a special jury instruction violating due process; and (3) ineffective assistance of trial and appellate counsel.
Trial court denied relief; the Fifth Circuit ordered an evidentiary hearing limited to factual questions about the surveillance footage. The district court held that hearing on June 24, 2015.
At the evidentiary hearing Detective Broussard testified he copied and delivered the disc to defense counsel and showed its contents to Cambrice; the disc (video + still photos) was admitted as a joint exhibit and played in court.
The court found the disc footage consistent with the victim’s testimony and Cambrice’s confession (that he robbed the victim and said the gun was not real), and concluded the material was not exculpatory and was not withheld.
The court denied all post‑conviction claims, concluding Brady and Strickland standards were not met, and that Cambrice had exhausted state post‑conviction remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady: State withheld exculpatory surveillance footage and reports	Cambrice: State suppressed a time‑stamped disc and reports that would exculpate him	State: Detective provided the disc to defense counsel and the footage is not exculpatory	Denied — evidence was disclosed and not exculpatory; Brady elements not met
Jury instruction refusal	Cambrice: Trial court’s refusal of special instruction prejudiced due process	State: Issue was previously denied and appellate remand limited to video facts	Claim already denied by trial court and not revived by limited remand; no relief granted
Ineffective assistance — trial counsel	Cambrice: Netterville failed to investigate and discover exculpatory evidence	State: Netterville was experienced, had the disc, and testimony supports he knew the evidence	Denied — petitioner failed to show deficient performance or prejudice under Strickland
Ineffective assistance — appellate counsel	Cambrice: Appellate counsel failed to investigate and raise meritorious issues	State: Appellate brief was reasonable; counsel may winnow issues strategically	Denied — petitioner did not show prejudice that would have changed appeal outcome

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose material exculpatory evidence)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong ineffective assistance standard)
Strickler v. Greene, 527 U.S. 263 (1999) (explaining Brady suppression and prejudice standards)
Kyles v. Whitley, 514 U.S. 419 (1995) (Brady does not require reversal unless suppressed evidence creates reasonable probability of different result)
Padilla v. Kentucky, 559 U.S. 356 (2010) (noting difficulty of overcoming Strickland’s standard)
Evitts v. Lucey, 469 U.S. 387 (1985) (appellate counsel not required to raise every nonfrivolous issue)
Jones v. Barnes, 463 U.S. 745 (1983) (appellate counsel may winnow issues)
State v. Legrand, 864 So.2d 89 (La. 2003) (Louisiana discussion of Strickland standard)
State v. Washington, 491 So.2d 1337 (La. 1986) (applying ineffective assistance standard in Louisiana)